DCT
1:25-cv-00845
Shen Zhen Nuo BEI Shi Chuang Yi Fa Zhan Co Ltd v. Che
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Shen Zhen Nuo Bei Shi Chuang Yi Fa Zhan Co., Ltd. and Shenzhen Mumuwan Maoyi Youxian Gong Si (China)
- Defendant: Xiaoling Che (China)
- Plaintiff’s Counsel: Aptum Law
- Case Identification: 1:25-cv-00845, N.D. Ill., 01/24/2025
- Venue Allegations: Venue is predicated on Defendant targeting business activities in Illinois through an interactive e-commerce store on Amazon.com. Personal jurisdiction is asserted based on Defendant having previously filed patent infringement lawsuits in the Northern District of Illinois.
- Core Dispute: Plaintiffs, sellers of puzzle boards, seek a declaratory judgment that their products do not infringe Defendant’s patent and that the patent is invalid, in response to Defendant’s infringement complaints to Amazon.com which resulted in the delisting of Plaintiffs' products.
- Technical Context: The technology involves puzzle platforms, or specialized boards, designed to facilitate the assembly of large jigsaw puzzles by providing a stable surface, edge guards, and storage.
- Key Procedural History: The action was initiated by the Plaintiffs after Defendant, a co-owner of the asserted patent, submitted infringement complaints to Amazon, leading to the removal of Plaintiffs’ products from the platform. The complaint notes that Defendant has previously filed patent litigation against other Amazon sellers in the same judicial district.
Case Timeline
| Date | Event |
|---|---|
| 2021-09-26 | ’885 Patent Priority Date |
| 2024-07-30 | ’885 Patent Issue Date |
| 2024-11 | Defendant lodges infringement complaints with Amazon |
| 2025-01-24 | Complaint for Declaratory Judgment Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,048,885 - "Movable puzzle platform"
- Patent Identification: U.S. Patent No. 12,048,885, "Movable puzzle platform," issued July 30, 2024.
The Invention Explained
- Problem Addressed: The patent’s background section identifies challenges associated with large-scale jigsaw puzzles, including the need for a large, dedicated playing surface, the difficulty for a player to reach all areas of the board without moving, and the risk of losing puzzle pieces ('885 Patent, col. 1:36-56).
- The Patented Solution: The invention is a "movable puzzle platform" designed to solve these issues. It consists of a board assembly with a main puzzle plate, an underlying supplement arrangement that can include drawers for piece storage, and a "restricting wall" around the perimeter to contain the pieces ('885 Patent, col. 6:1-15). A central feature of the claimed invention is a specific multi-layered construction where an "extending wall" and a "fixing portion" are "successively stacked on" a "main supporting wall" ('885 Patent, Abstract).
- Technical Importance: The platform aims to provide a comprehensive, self-contained, and convenient system for puzzle enthusiasts, allowing them to assemble, store, and manage large puzzles more effectively ('885 Patent, col. 1:57-62).
Key Claims at a Glance
- The complaint asserts non-infringement of independent claims 1 and 23 ('885 Patent, col. 25:1-26:60; Compl. ¶19).
- Independent Claim 1 requires, among other elements:
- A board assembly with a puzzle board (comprising a puzzle plate and a fixing portion).
- A supplement arrangement with a first main supporting wall attached to the puzzle board's bottom surface.
- A restricting wall with a first extending wall that is stacked on the fixing portion.
- A requirement that "the first extending wall and the fixing portion of the puzzle board are successively stacked on the first main supporting wall."
- A second main supporting wall and a second extending wall with a similar "successively stacked" requirement.
- The complaint seeks a declaration of non-infringement as to all claims of the patent, implicitly including all dependent claims ('885 Patent, col. 26:61-28:32; Compl. ¶37).
III. The Accused Instrumentality
Product Identification
- Plaintiffs' "Puzzle Board Products," identified by Amazon ASINs B0D49HG8GF, B0CZCSVXKW, B0CYW9MQST, and B0CNSS2S59 (Compl. ¶12, fn. 1).
Functionality and Market Context
- The accused instrumentalities are wooden puzzle boards sold through Amazon.com (Compl. ¶¶1, 8, 27). The complaint alleges they are among the "top ten bestselling puzzle board products on Amazon.com" ('Compl. ¶8).
- The central technical feature at issue is the construction of the product’s side walls. The complaint provides annotated photographs to distinguish the product's construction from the structure claimed in the ’885 Patent (Compl. p. 7). For example, "Photo #1 of Plaintiffs' Puzzle Board Products; annotated" depicts two wooden blocks connected to a wood plate at different, non-overlapping locations (Compl. p. 7).
IV. Analysis of Infringement Allegations
Note: As a declaratory judgment action, the following summarizes Plaintiffs' allegations of non-infringement.
'885 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| wherein, the first extending wall and the fixing portion of the puzzle board are successively stacked on the first main supporting wall | Plaintiffs allege their product lacks this element because its components are not "successively stacked." Instead, they allege that an extending wall and an extending portion are attached alongside each other to a supporting wall, not vertically layered on top of one another as depicted in the patent. | ¶¶20, 28 | col. 25:11-14 |
| ...the restricting wall further comprises a second extending wall... wherein the second extending wall and the fixing portion of the puzzle board are successively stacked on the second main supporting wall. | As with the first extending wall, Plaintiffs allege this limitation is not met because their products do not feature the required "successively stacked" structure. | ¶¶20, 28 | col. 25:19-24 |
Identified Points of Contention
- Scope Questions: The primary dispute concerns the meaning of "successively stacked on." The complaint asserts this requires a specific vertical layering of components, as shown in the patent’s Figure 53 (Compl. p. 6), and that the accused product’s adjacent, non-layered construction falls outside this scope (Compl. ¶28). The case raises the question of whether the claim language can be interpreted more broadly to read on different structural arrangements.
- Technical Questions: A key factual question will be comparing the physical structure of the accused products with the configuration claimed in the patent. The complaint leverages "Figure 53 of the '885 Patent; annotated" to illustrate the claimed vertical stack of elements (Compl. p. 6), contrasting it directly with photographs of its own product to argue for a fundamental structural difference (Compl. p. 7).
V. Key Claim Terms for Construction
- The Term: "successively stacked on"
- Context and Importance: This term is central to the non-infringement argument. The Plaintiffs’ entire literal infringement defense, as presented in the complaint, relies on a narrow interpretation of this phrase that excludes their product’s design. Practitioners may focus on this term because its construction will likely be dispositive of literal infringement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A defendant might argue that in the context of the invention, "stacked on" does not require precise vertical alignment but refers more generally to a layered assembly where components are placed in a sequence relative to the main supporting wall. The patent does not appear to provide an explicit definition that would support this.
- Evidence for a Narrower Interpretation: The complaint argues for a narrow construction based on the patent’s explicit language and figures. The phrase "successively stacked" is used consistently in the patent's abstract, summary, and claims to describe a specific layered structure ('885 Patent, Abstract; col. 2:10-13; col. 25:11-14). This interpretation is visually supported by embodiments like Figure 53, which depicts a clear vertical alignment of the "first extending wall" (50f), "fixing portion" (102f), and "first main supporting wall" (301f) ('885 Patent, Fig. 53).
VI. Other Allegations
The complaint does not provide sufficient detail for analysis of indirect or willful infringement. It seeks a declaration of non-infringement for "any claim of the '855 Patent," including direct and indirect infringement, and requests a finding that the case is exceptional, but does not plead specific facts related to inducement, contributory, or willful infringement theories (Compl. ¶¶39, Prayer for Relief D).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction: Can the term "successively stacked on," which the patent illustrates as a direct vertical layering of components, be construed to cover the accused product's structure where components are attached adjacently to a supporting wall rather than on top of one another?
- A second critical issue will be the doctrine of equivalents and public dedication: If the accused products are found not to literally infringe, the focus will shift to equivalence. This will test the Plaintiffs' argument that the patentee disclosed but did not claim alternative embodiments (e.g., a single-layer structure), thereby dedicating that subject matter to the public and barring a finding of infringement under the doctrine of equivalents (Compl. ¶¶32-35).
- A key evidentiary question will be one of invalidity: The complaint makes a conclusory allegation of invalidity based on two YouTube videos cited as prior art (Compl. ¶¶43-44). A central question for discovery will be whether the content of these videos, once produced, actually discloses every element of the asserted claims prior to the patent's priority date.